COUNTY OF VERMILIONLocal Government

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). Condition: Several purchases for Federal awards did not complete the suspension and debarment procedures prior to entering into the transactions. Questioned costs: None Context: In the testing of 4 of 8 of the suspension and debarment transactions has not been completely followed per the Uniform Grant Guidance. Cause: The processes for suspension and were not properly followed during the current fiscal year. Effect: A lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding: 2022-002 Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation. Views of responsible officials: The County recognizes and accepts the audit finding as presented.

Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). Condition: The County did not complete the suspension and debarment procedures prior to entering into the transactions. Questioned costs: None Context: The County?s suspension and debarment policy has not been completely followed per the Uniform Grant Guidance. This was noted in the 5 out of 5 items tested. Cause: The processes for suspension and debarment where updated and approved near the end of the current fiscal year as a result of the prior year finding. However, the updated procedures were not implemented for the full year which resulted in the majority of the current year?s transactions following the old procedures. Effect: A lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding: The finding is a repeat of the finding in the immediately prior year. Prior year finding number was 2021-002. Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation.

Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring that supporting calculations are accurate. Condition: The County made errors in its support summarizing/reconciling its allowable costs, when reporting the funds it spent under COVID-19 State and Local Fiscal Recovery Funds, overclaiming $7,125 cumulatively during the fiscal year. In addition, there is no formal documentation of the review being completed. Questioned costs: $7,125 Context: The County made errors on the amounts reported in 4 out of 4 reports tested, cumulatively overclaiming $7,125 during the fiscal year. Cause: Costs were paid accurately to employees and vendors, but, incorrectly allocated and charged to the grant due to adjustments/allocations made in subsequent periods. Effect: May result in unallowable costs being charged to Federal programs. Repeat finding: No. Recommendation: We recommend the County review its procedures relative to allocating costs and reviewing support provided for reporting to Federal programs.

FINDING 2021 ? 002 Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: March 3, 2021 ? December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: The County did not provide supporting documentation to detail the history of the procurement as required by Uniform Grant Guidance. In discussion with the client and with the supporting documentation that was provided, there was evidence that the procurement process did occur, however the documentation was not maintained or adequately documented. Questioned costs: None. Context: The County?s procurement policy has not been completely updated to Uniform Grant Guidance for documentation to retain. Cause: The procurement policy should have written policies and procedures to be in compliance with Uniform Grant Guidance. Effect: A lack of internal control procedures can lead to noncompliance with grant requirements. Repeat Finding: None. Recommendation: We recommend updating the procurement policy per the Uniform Guidance and retain required documentation. Views of responsible officials: The County recognizes and accepts the audit finding as presented.

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